When it comes down to disclosing tax liabilities for accounting purposes for optimal reliability of financial statements, little weight seems to be given to the legal dimension in setting financial reporting standards. While it may be argued that a criminal charge is not to be considered ‘imminent’ when accounting standards require disclosure of contingent tax liabilities revealing previous tax offences, a violation of Article 6 ECHR may be more obvious in cases where a penalty has already been imposed and court proceedings are pending.